Smoky Hollow Foods - Executive Summary |
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EXECUTIVE SUMMARY Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Smoky Hollow Foods, Inc. (Smoky Hollow) submits this Risk Management Plan (RMP) for operations at their Little Rock, Arkansas, facility. Smoky Hollows operations include the manufacturing of pork and beef food products for public consumption packaged under the familiar brand name Smoky Hollow. Smoky Hollow has been in operation at this facility for over 21 years providing quality meat products and over 400 jobs to the local community. Accidental Release Prevention and Emergency Response Policy Smoky Hollow is committed to protecting the health of its employees, the surrounding community, and the environment; therefore it is Smoky Hollows policy to maintain compliance with 40 CFR 68 as well as Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations, Chapter 1910, Section 119 (29 CFR 1910.119), and OSHAs Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). Stationary Sources and Regulated Substances Smoky Hollow is subject to 112(r) because ammonia, a regulated substance, is present at the facility in amounts greater than 10,000 pounds; Smoky Hollow is required to maintain low temperatures in the food processing areas of the plant that are within standards required by the United States Department of Agriculture (USDA) to ensure quality in the final products. Smoky Hollow uses anhydrous ammonia (a 112(r) regulated substance) as a refrigerant to maintain the facility within the required range of operating temperatures. Anhydrous ammonia is an industry-standard refrigerant for meat processing plants. Smoky Hollows refrigeration system, consisting of receivers, compressors, evaporators, condensers, and piping, can contain a maximum amount of 62,000 pounds of anhydrous ammonia. Worst Case Release Scenario As required by 40 CFR 68 Subpart B, Smoky Hollow has evaluated a worst-case release scenario for anhydrous ammonia using the parameters specified by the EPA. The worst-case release scenarios were developed following EPA regulations and are not considered to be likely release scenarios. Ammonia Smoky Hollows worst case release scenario for ammonia is a 1/2 Safety Relief Valve failing on the High Pressure Receiver (7470 pounds when filled to 100% capacity) over a 60-minute period. Using ALOHA version 5.2.1 and the International Institute of Ammonia Refrigeration (IIAR) interim final draft document, Risk Management Program Guidance (40 CFR Part 68) for Ammonia Refrigeration, 1998 (Refrigeration Guidance), the maximum distance to the toxic endpoint extends offsite. During normal operations, Smoky Hollow maintains the receiver at no more than 50% capacity. Only during emergency or failure does the receiver have the potential to be f illed to 100% of capacity. Alternative Release Scenario Ammonia A more realistic release scenario (alternative release) was developed by Smoky Hollow taking into consideration operational history and the hazards identified in the process hazard analyses (PHAs) conducted under the Occupational Safety and Health Administration OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119). A likely release scenario identified by Smoky Hollow would be a release caused by a leaking 1/2 liquid solenoid valve bonnet. This release could occur as a result of vibration loosening the valve bonnet nut allowing pressure to leak out between the nut and the plunger. In developing the release parameters of this alternative scenario, Smoky Hollow considered other possible scenarios and the average response time of the facilitys HAZMAT team. Using ALOHA Version 5.2.1 and the Refrigeration Guidance document s procedures for estimating release values, the toxic endpoint extends offsite. Accidental Release Prevention Program Ammonia To prevent and mitigate accidental releases of anhydrous ammonia, Smoky Hollow has implemented several precautionary measures. Smoky Hollow has developed and implemented a PSM program pursuant to OSHA regulations and as such, has evaluated the system for the potential of anhydrous ammonia releases. Some of the controls installed to prevent catastrophic releases of ammonia are process equipment (vents, pressure relief valves, backup pumps, and manual shutoffs) and automated controls (automatic shut-offs and electrical distribution system grounding). In addition, Smoky Hollow has trained approximately 14 personnel to respond to potential ammonia releases (HAZMAT team). Smoky Hollow has developed standard operating procedures for all employees and contractors that have contact with the refrigeration systems that incorporate safety measures into the procedure s. These safety procedures were developed by system operators and are reviewed at a frequency sufficient to assure that they reflect current operating practice, including changes that result from changes in the technology, the equipment and the facility. Smoky Hollow encourages employee participation in development of the control measures used at the plant by means of company newsletters and training sessions. Pursuant to written management of change procedures established by Smoky Hollow, any changes to the operating procedures are communicated to affected employees. Smoky Hollow understands that maintaining the refrigeration systems in good working order is essential to preventing accidental releases; therefore Smoky Hollow has implemented preventative maintenance programs. Each preventative maintenance program is scheduled, documented and managed using log sheets to ensure that regular maintenance occurs on the system. These log sheets are maintained in the Maintenance Depart ment for three years. Also, to ensure the mechanical integrity of critical system components, equipment tests are performed. Specifically, the equipment is tested to detect corrosion. Refrigeration equipment consists of pressure vessels, headers, and piping. To ensure that Smoky Hollows control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits are performed on the refrigeration system: 7 In accordance with the PSM program, Smoky Hollow conducts detailed PSM compliance audits at least every three years, typically annually. Each audit incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, management of change, pre-start up review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. 7 In addition, Smoky Hollow is audited by the lo cal fire department on an annual basis. 7 Smoky Hollow is audited by the USDA on an continual basis. The USDA maintains a team of personnel at the Smoky Hollow facility. 7 Smoky Hollows insurance carrier also conducts independent audits on an variable annual to biennial basis. Five-Year Accident History Ammonia Within the five years prior to the submittal of the RMP plan, there have been no accidental releases of anhydrous ammonia that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency Response Program Smoky Hollow has documented emergency response procedures in a document entitled Emergency Response Action Plan (ERAP) in order to facilitate response efforts in the event of an off-site hazardous substance release. Included in the ERAP are measures to be taken internally by Smoky Hollow as well as measures to be taken by off-site response agencies. Smoky Hollow has trained approximately 14 on-site personnel to respond to accidental hazardous substance releases. These personnel are trained in accordance with 29 CFR 1910.120, OSHAs Hazardous Waste Operations and Emergency Response regulations according to their duties and function. These personnel receive initial training and annual update training thereafter. To assure that the local governmental response agencies are familiar with Smoky Hollows emergency response procedures, Smoky Hollow will provide copies of the ERAP and future major revisions for review by the Pulaski County Office of Emergency Services (OES). To plan for a hazardous substance release with off-site effects, Smoky Hollows ERAP includes procedures/equipment to mitigate the release, procedures to inform local response agencies, evacuation procedures, and procedures for public communication. In addition to the Pulaski County Office Of Emergency Services, Smoky Hollow has arranged emergency resp onse assistance with a local clean-up contractor: Safety Kleen Inc. In the event of a hazardous substance release with off-site effects, the general public will be warned using the following methods: 7 Police and fire vehicles equipped with public address systems, and 7 Door-to-door notification of residents (if time permits). |